Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Reassessment under section 147 was invalid where the AO reopened the case on AIR information on the premise that the assessee was a non-PAN holder and had not filed a return, although the original return had already disclosed the property transfer, capital gains particulars and exemption claim. The Tribunal also found that the statutory notice under section 148, which confers jurisdiction for reassessment, was never served and no effective attempt at service was shown. As the reopening was also initiated beyond six years from the relevant assessment year, the reassessment was held to be without jurisdiction and void ab initio.
Reassessment under section 147 was invalid where the AO reopened the case on AIR information on the premise that the assessee was a non-PAN holder and had not filed a return, although the original return had already disclosed the property transfer, capital gains particulars and exemption claim. The Tribunal also found that the statutory notice under section 148, which confers jurisdiction for reassessment, was never served and no effective attempt at service was shown. As the reopening was also initiated beyond six years from the relevant assessment year, the reassessment was held to be without jurisdiction and void ab initio.
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